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Members of the Federal Financial Institutions Examination Council on Tuesday released new Home Mortgage Disclosure Act examiner transaction testing guidelines for all financial institutions – including credit unions – that report HMDA data.

These guidelines will be used by all supervisory agencies and will apply to HMDA data collection examinations beginning in 2018 and reported beginning in 2019.

The guidelines describe to examiners how to validate the accuracy of HMDA data collected and the circumstances under which they may have a financial institution correct or resubmit their data. Topics covered include HMDA transaction testing procedures, tolerances, ethnicity or race data errors, prospective changes and HMDA transaction testing sample sizes and thresholds. Examples are also included in the six-page guidelines.

The CFPB explained in a blog post Tuesday that these guidelines, in light of the new data fields that are required beginning next year, will eliminate the file error resubmission threshold, establish allowable tolerances for certain data fields and provide a 10 percent field error resubmission threshold for financial institutions with loan application register counts of 100 or less.

Most of the new HMDA requirements become effective Jan. 1, 2018. They affect home equity lines of credit, establish transactional thresholds for coverage and expand the number of HMDA data points collected from credit unions.

Earlier this month, NAFCU urged an exemption from HMDA reporting for all HELOCs or, in the alternative, higher reporting thresholds for close-end and open-end loans following a CFPB proposal to temporarily raise the HELOC reporting threshold, making it effective for 2018 and 2019.

NAFCU has a host of HMDA compliance resources available to association members, including charts and guides, articles, webcasts and blog posts.